31 EPA Compliance Testing Important that manufacturers submit certification and production plans Ensures timely selection and performance of compliance testing See CD (March 2013) for further instructions Information o on preparing for confirmatory o testing available at Set up requirements Test engine information sheet Information on selective enforcement audits can be found at 40 CFR Part 1068, Subpart E U.S. Environmental Protection Agency 31

45 Fuel Sulfur % is an Operational Requirement Low Sulfur Fuel Oil (LSFO) is currently required for all operation within the ECA Vessels must switch to 1.0% S fuel* Typically a blended product of residual and distillate fuel oil Requirement of 0.1% fuel sulfur beginning January 1, 2015 may mean switch to mostly distillate fuel Alternate means to address this requirement Annex VI and Part 1043 allow EPA to approve the use of fuels not meeting this requirement provided that the vessel applies a method that results in equivalent emission reductions (e.g., exhaust scrubbers are now under review by EPA for use under this equivalent controls section) EPA reviewing and in dialog with some manufacturers regarding CNG and LNG / diesel (pilot) dual fuel applications (mode in and out for ECA use) * Certain exceptions apply for Great Lakes only vessels ( ) U.S. Environmental Protection Agency 45

47 How is ECA Enforced? Enforcement coordinated between Coast Guard and EPA (largely OECA) via MOU Additional details on MOU included in appendix Both U.S. and foreign-flagged vessels are subject to ECA requirements and enforcement 90% of annual U.S. port visits are under foreign flag OTAQ role includes engine certification, manufacturer education and assistance, and review of various compliance reports Fuel Oil Notice of Availability Reports (FONARs), permit and exemption requests U.S. Environmental Protection Agency 47

49 How has the ECA worked so far? Monthly FONARs received were initially more than 200 (July 2012), and those citing US ports were 70+ Dwindled down rapidly at year s end to a few dozen Initially, vessel owners worried that they would have to wait for EPA response before proceeding on voyage Operation with non-compliant fuel oil is technically a violation Submission of FONAR considered admission of violation and request for enforcement discretion Voyage may continue without upon filing no EPA response necessary Reports of suppliers requiring minimum LSFO purchase (or even accompanied by a minimum HSFO purchase) were forwarded to OECA for action Coast Guard has only detained 3 ships in the U.S. so far U.S. Environmental Protection Agency 49

50 Fuel Oil Non-Availability Reporting Annex VI allows for a case where compliant fuel is not available E.g., a vessel sails from Brazil, where 1% bunker is not available, to Philadelphia Guidance released 06/26/12 uelavailabilityguidance-0626.pdf id df Reports now submitted through FOND (Fuel Oil Non-Availability Disclosure): mobile/fondinstructions.pdf Does not require distillate before Requires report to USCG/EPA (= Fuel Oil Non-Availability Report / Fuel Oil Non-availability Disclosure) Case specific Frequent caller vs. once every year or less Port of origin How did they attempt to obtain compliant fuel Requires that they get compliant fuel in first US port of call U.S. Environmental Protection Agency 50

52 International Air Pollution Prevention Cert. Required for inspected vessels greater than 400 gross tons engaged in international routes USCG issues, amends, revokes Pre-cert inspection includes: SOx Bunker Delivery Notes Bunker Samples Ozone Depleting Substances (ODS) New installations of ODS prohibited after May 19, 2005 (with the exception of HCFCs, which are permitted until January 1, 2020) Shipboard Incineration Volatile Organic Compounds If a vessel is equipped with a vapor recovery system, the system must be in compliance with 46 CFR Part 39 U.S. Environmental Protection Agency 52

54 MOU between EPA and USCG to Enforce Annex VI USCG and EPA entered into a Memorandum of Understanding on June 27, 2011 to enforce the provisions of MARPOL Annex VI U.S. Environmental Protection Agency 54

55 MOU Significant Provisions USCG and EPA agree to mutually cooperate in implementing Annex VI USCG and EPA agree to jointly develop protocols for carrying out enforcement activities iti on board ships, in ports and at facilities Roles are based primarily on each agency s areas of expertise USCG has primary authority to conduct ship inspections, examinations and investigations. EPA may request to or USCG may request that EPA attend or assist in on board activities. EPA has primary authority to verify compliance with fuel oil availability and quality requirements (shore side fuel requirements) Both USCG and EPA have authority to take enforcement actions. Actions may be referred from one agency to the other U.S. Environmental Protection Agency 55

59 Defect and Recall Reports Part 85 - HD Highway Electronic reporting system (EDIR/VERR System) Reporting documents and instructions can be found at Part NRCI and other categories Hardcopy reporting following regulation format Recommend electronic copy Submit to Justin Greuel, your EPA cert rep, Cliff Dean and Michelle Ibarra Contractor assists with internal EPA database Plan to include nonroad reporting in Verify in the future U.S. Environmental Protection Agency 59

60 DR Preparation Tips Follow the regulation format ( (d)) If some information not available when DR initially filed, provide reason and amend DR as soon as information available. Amend DR if information significantly revised Most common area for follow-up is defect description (c)(2), (d)(3) U.S. Environmental Protection Agency 60

61 Defect Description - continued EPA looking for enough information to clearly identify device, system or assembly which has the defect, what the defect is and to the extent known at the time, the cause of the defect EPA most likely to request est follow-up information when aftertreatment devices affected: Greatest emissions impact Many variables can affect Occasionally request root cause information U.S. Environmental Protection Agency 61

63 EPA Activity Beginning to review manufacturers in-house defect monitoring and reporting processes Have begun with nonroad sector Plan to work with at least 1-2 manufacturers per year Finalizing i modifications to in house database to incorporate 1068 Investigation Reports, etc. Plan to better incorporate knowledge gained from defect reporting into new engine certification U.S. Environmental Protection Agency 63

67 Compliance Programs Compliance programs verify compliance with emission requirements at different stages of an engine s useful life, in accordance with the spirit of the Clean Air Act. Certification Data generated under compliance programs feed information back into the certification process. It provides a means of evaluating the reliability of data submitted during certification. AB&T PLT In-use Production TPEM U.S. Environmental Protection Agency 67

68 Manufacturers Reporting Obligations Dear Manufacturer Letter CD (October 2012) Reminder to manufacturers of various reporting obligations Announces new process for submitting reports through the VERIFY Document Module Instructs manufacturers to begin using templates for reporting and to submit past due reports Found at: htm Failure to report may result in: Referral of violation to OECA for possible assessment of civil penalties Revocation, suspension, or voiding of current or prior model year certificates Denial of new certificates Adobe Acrobat Document U.S. Environmental Protection Agency 68

69 How to Submit Compliance Reports Use EPA-provided, Excel-based templates Templates found at Templates are updated periodically. Check for new versions. Facilitates compiling of information in internal database Data will be reviewed in conjunction with certification We may contact you if reports are missing. Submit compliance reports through VERIFY Submit questions / comments about HD/NRCI templates to Jason Gumbs Submit questions about compliance programs to your EPA certification representative Do not submit TPEM equipment manufacturer documents via VERIFY Check your records make sure you have submitted all your reports U.S. Environmental Protection Agency Bitmap Image Bitmap Image 69

70 How to Submit Compliance Reports Guidance on how to successfully submit through VERIFY Click on Engine Certification and Compliance Guidance Documents Note instructions on how to name your reports Bitmap Image Label corrections clearly Do not or mail copies of reports May not be processed U.S. Environmental Protection Agency 70

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